SC&A

46

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SC&A 4-23 Sol. No. 2003-N-00768


Due to the importance of ensuring that assumptions used to estimate doses are fair, consistent,
and scientifically grounded, a special topic that must be re-emphasized is the need to compare all
available data (i.e., worker profile data, site profile data, work history interview, claimant
documentation, etc.) and evaluate them for consistency and reasonableness. Data comparisons
should not be limited to information available for an individual case, but when applicable, should
also include comparisons between similar cases.

3.8.9 Auditor’s Assessment of a Case Significantly Differs with NIOSH’s Dose Reconstruction
Results

There may be cases during the basic, advanced, or blind review where the auditor identifies new
information or uncovers inappropriate/unreasonable assumptions, calculational errors,
inconsistencies in data, etc., that will substantially increase the dose and potentially change the
outcome of a denied claim. When it appears that the auditor’s findings could result in a PC of
greater than 50 percent, it is recommended that the auditor(s) have an opportunity to present this
case to the Advisory Board for further review.

SC&A 3-40 Sol. No. 2003-N-00768


SC&A 4-10 Sol. No. 2003-N-00768


SEC PETITION REVIEW CHECKLIST
continued

Exhibit 3-2. SEC Petition Audit Report and Checklist (continued)

Description

[vesnoma |

Comments Initials

Gii) “Primary cancer of the:

(A) Thyroid?

(B) Male or female breast?

(C) Esophagus?

(D) Stomach?

(E) Pharynx?

(F) Small intestine?

(G) Pancreas?

(H) Bile ducts?

() Gall bladder?

(B) Salivary gland?

(K) Urinary bladder?

(L) Brain?

(M) Colon?

(N) Ovary?

(O) Liver (except if cirrhosis or hepatitis B
is indicated)”?

. Has the petitioner provided proof of the cancer diagnosis

(e.g., physician’s letter, post-mortem exam results)? Note:

Proof of diagnosis is not discussed in 42 CFR 83, but it
may be important for the purposes of evaluation.

PETITION REQUIREMENTS
Sentences or phases in quotations are items taken directly from 42 CFR 83.
Does the petition indicate or contain:

. “The DOE or AWE facility at which the class worked”?

. “The location or locations at the facility covered by the
etition (c.g., building, technical area)?”

‘The job titles and/or job duties of the class members?”

4. “The period of employment relevant to the petition?”

5. “Identification of an exposure incident that was

unmonitored, unrecorded, or inadequately monitored or
recorded?” Some examples include:

(i) Records or confirmation from NIOSH or DOE that

the exposure incident occurred?

(ii) “Medical evidence that one or more members of

the class may have incurred a high-level radiation dose
from the incident, such as a depressed white blood cell

count associated with radiation exposure or the
application of chelation therapy”?

ii) “Confirmation by affidavit from two employees

who witnessed the incident, providing this evidence is

consistent with other information available to HHS?”

SC&A 3-31

Sol. No. 2003-N-00768


SC&A

421

Sol. No. 2003-N-00768


SC&A

Sol. No. 2003-N-00768


SC&A 413 Sol. No. 2003-N-00768


SC&A 49 Sol. No. 2003-N-00768


SC&A 422 Sol. No. 2003-N-00768


g
3
3
Z| ¢
Name, Title, 3 6
Anticipated Level of Effort Educational g g Familiar with Specific DOE/AWE
(key personnel only) Background > é Facilities

SC&A i Sol. No. 2003-N-00768


3.8.2 Use of Specific Values of the Human Respiratory Tract Model (HRTM) Parameters

A great deal of attention is currently being given to the appropriate choice of the absorption
parameters in performing internal dose calculations. For example, though particle sizes have
been considered important since the issuance of ICRP 30, concern regarding specific absorption
parameters and their effect on bioassay is new. This issue is given particular attention in the
recently published “Guide for the Practical Application of the ICRP Human Respiratory Tract
Model,” Annals of the ICRP, Supporting Guidance No. 3, Volume 32, No. 1-2, 2002, ISN 0146-
6453, Pergamon Press, 2003.

In this document, guidance is given on applying the HRTM in situations that require specific
information on the characterization of radioactive aerosols and gases, and on determining
absorption rates from lungs to the blood. The information contained in this document is a very
important update on the ICRP 66, 68,78, (56, 67, 69) series, and should be used in the
interpretation of bioassay data and when it is desirable to obtain better dose assessments.
Examples are given illustrating the application of the HRTM in a range of situations. The
document analyzes how specific information on particle-size distribution, particle density,
absorption to blood, nose or mouth breathing, and distribution of time between sleep, sitting, and
light/heavy exercises affects the effective doses and the interpretation of bioassay measurements
(urine, feces, lungs). In general, bioassay measurements change much more than effective doses,
as the characteristics of the inhaled material change. So it may well be particularly important to
use specific information to assess intakes from measurements on workers.

Jn the reconstruction of doses we may use material-related parameters that result in a better
assessment of the dose. When particle-size distribution is unknown, and available data are not
sufficient for determining the particle size, dose should be calculated using “dose per measured
quantities” (urine excretion, feces excretion, lung, or body measurements). The quantity
“dose/measured quantity” is more robust in relation to particle sizes than the quantity
“{ntake/measured quantity,” although they come from the same ICRP models and the former
value is obtained by multiplying the last one by the quantity dose coefficient per unit intake.
Specific absorption factors, describing the rate of absorption from lungs to blood, should be used
for compounds described in this document and when a more refined dose reconstruction analysis
is required.

In any particular situation, the actual values of many of the parameters will inevitably be different
from the reference values. There can be circumstances in which it is feasible and desirable to
obtain a more accurate, or more reliable assessment of intake or dose, by using information
specific to the situation. Typically, this is likely to be the case when assessing doses
retrospectively, i.e., when the intake has already taken place, or when intakes are currently taking
place or are likely to take place in. the near future.

In general, a “closer look” at absorption parameters generally reveals that the default values used
to derive the generic dose conversion factors are overly conservative. This creates a dilemma for
this project in that it is our intent to err on the side of the claimant. As such, our audits will
identify such issues as they arise, solely for the purpose of providing a complete record of our
review, but this does not necessarily mean that NIOSH was incorrect in using the more
conservative default values in their assessments. In cases in which the reconstructed doses are

SC&A 3-36 Sol. No. 2003-N-00768


SC&A 4-19 Sol. No. 2003-N-00768


SC&A

4-16

Sol. No. 2003-N-00768


Exhibit 3-2. SEC Petition Audit Report and Checklist (continued)

SEC PETITION REVIEW CHECKLIST

continued

Description

Comments | Initials

YesINo/NA_|

TYPES OF INFORMATION USED IN DOSE RECONSTRUCTION
Taken directly from 42 CFR 82.14.
This is simply a guideline. Each case is different and not all of the types
of information listed below may be necessary.

1. “Subject and employment information:”

(a) “gender”

(b) “date of birth”

() “DOE and/or AWE employment history:

(i) job title held by year

(ii) work location (site names, building numbers,
technical areas, duration of relevant
employment)”

2. “Worker monitoring data”:

(a) “external dosimetry data (film badge, TLD,
neutron dosimeters)”

(b) “pocket ionization chamber data”

3. “Internal dosimetry data:”

(a) “urinalysis results”

(b) “fecal sample results”

(c) “in vivo measurements results”

(d) “incident investigation reports”

(e) “breath radon and/or thoron results”

(f) “nasal smear results”

(g) “external contamination measurements”

(h) “other measurement results applicable to internal
dosimetry”

4. “Monitoring program data”

(a) “analytical methods used for bioassay analyses”

(b) “performance characteristics of dosimeters for
different radiation types”

(c) “historical detection limits for bioassay samples
and dosimeter badges”

(d) “bioassay sample and dosimeter
collection/exchange frequencies”

(e) “documentation of record keeping practices used
to record data and/or administratively assign dose”

(f) “other information to characterize the monitoring
‘ogram results”

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Sol. No. 2003-N-00768


Exhibit 3-2. SEC Petition Audit Report and Checklist (continued)

SEC PETITION REVIEW CHECKLIST

continued

L Description

Yes/No/NA.

Comments Initials

6. “A description of the petitioner’s basis for believing
records and information available are inadequate to
estimate the radiation doses incurred by members of the
proposed class of employees with sufficient accuracy?”
Some examples include:

(@® “Documentation or statements provided by
affidavit indicating that radiation exposures and doses
to members of the proposed class were not monitored,
either through personal or area monitoring”?

(i) “Documentation or statements provided by
affidavit indicating that radiation monitoring records
for members of the proposed class have been lost,
falsified, or destroyed”?

(iii) “A report published by a scientific government
agency or published in a peer-reviewed scientific
journal that identifies dosimetry and related
information that are unavailable for estimating the
radiation doses of employees”?

INFORMATION GATHERED BY NIOSH

Sentences or phases in quotations are items taken directly from 42 CFR 83.

Does the administrative record contain information (or indicate attempts to obtain information)
from the following sources?

[i . Records and information from DOE and AWE facilities?

2. “Potential members of the class and their survivors?”

3. “Labor organizations who represent or represented
employees at the facility during the relevant time period?”

4. “Managers, radiation safety officials, and other witnesses
present during the relevant period at the facility”?

populations and records from dose reconstructions

5. “NIOSH records from epidemiological research on DOE
conducted under 42 CFR 82”?

6. “Records from research, dose reconstructions, medical
screening programs, and other related activities conducted
to evaluate the health and/or radiation exposures of
employees of DOE, DOE contractors or subcontractors,
and the AWEs”?

SC&A 3-32

Sol. No. 2003-N-00768


‘ears of Relevant

Name, Title, 6
Anticipated Level of Effort Educational 3 Familiar with Specific DOE/AWE
ersonnel onl} Bi yund Zz Facilities Availability

SC&A Sol. No. 2003-N-00768


3.8 Special Topics

The following presents a list and brief description of special technical topics that our team will be
prepared to address. Section 3.6 on Blind Dose Reconstruction also addresses many special
topics, especially those related to internal dosimetry.

3.8.1 Special Attention to Historical Bioassays and Dose Reconstructions

Historic bioassay surveillance data in workers have been evaluated at times by dosimetrists and
epidemiologists in order to reconstruct the extent of occupationally received past exposures to
one or more internally absorbed radionuclide-contaminants. Before those early data could be
employed in a meaningful interpretive manner, however, various essential defining
characteristics should have been addressed. For example, how technically accurate and precise
were the measurements, and to what extent were they representative of their associated exposure
events? Within this basic concept, we will endeavor to determine the extent to which statistical
confidence was attached to the archival surveillance data; consider any algorithm that may have
been employed for translation of older information into more current representations of
exposures; examine those programs for evaluating error terms which were attached to each of the
individual bioassay values; and consider how the original sample collection protocols were
considered for their effect on the final estimation of the time-course and magnitude of related
exposure(s).

To accomplish these aims, the approach that will be taken in this review can be represented as
falling into each of three major categories: (1) the statistical representation of analytical accuracy
and precision, (2) those factors accounting for the sample collection variability, and (3) the
biological considerations for estimating the physiological dose and significance. In the first
category, it will be necessary to statistically propagate the uncertainties associated with each of
the procedural steps (e.g., chemical and plating recoveries, detection efficiency, etc.), as well as
to consider the myriad of other factors that make up the statistical counting error (e.g.,
background variability, sample size, counting time, etc.). In addition, other sources of
uncertainty, such as the specificity of the analysis for the contaminant in question and individual
analytical procedural steps (e.g., plating problems resulting in unwarranted alpha particle
absorption), should be defined quantitatively. All of these considerations become particularly
significant when procedures entailing no tracer isotope (as frequently encountered in some of the
early methodologies) had been employed.

The second category that will be considered, i.e., the sample collection variability, includes
factors such as the magnitude, time, and frequency of the bioassay sample collection (important,
for example, to the extent defined by the changing pH of a standing urine sample, container—wall
“plateout,” magnitude of the “retention” parameter viz. effective half-life), as well as other time-
related collection factors that are relevant to the exposure scenario.

Finally, attempts at quantifying the above considerations for final radiological dose calculation
necessarily invokes knowledge of the physical absorption along with the uncertainties attached to
the magnitude of each of the metabolic transfer factors and deposition parameters of the
considered contaminant.

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SC&A 41 Sol. No. 2003-N-00768


adequacy, given the inherent difficulty of establishing routine tritium exposure and what internal
residence times can be assumed.

For an SEC evaluation, the circumstances at Paducah Gaseous Diffusion plant exemplify how
“missed dose” must be ascertained and evaluated. A number of sources of missed dose existed
that made it less feasible to estimate individual worker doses, including:

. A lack of documentation. At Paducah, this included doses that were never
recorded, may have been discarded, or records that could not be located after an
extensive search.

. A failure to monitor the exposure. There were numerous examples at Paducah
during the history of the plant where the potential for radiological exposure may
have existed, but was not monitored, or not adequately monitored.

. A failure to recognize an opportunity for a radiological exposure. For example, at
Paducah, it was assumed that nearly all uranium ingested or inhaled was soluble
and quickly excreted from the body without harm or long-term effects. In fact,
aerosols of insoluble uranium compounds were generated in a number of work
areas.

. Lack of sensitivity of the radiation monitoring or bioassay techniques. For
example, a worker who had been exposed to elevated airborne concentrations of
“poorly soluble” uranium was given in vivo radiation monitoring and determined
to be below standard detection limits for the site, when, in fact, the determined
lung burden was equivalent to a “significant internal deposition” according to
corporate radiation protection criteria.

. Movement of workers between job assignments and between facilities without
any documentation or changes in dosimetry to reflect differences in radiation
source terms. It was also obvious that, over time, buildings were used for
different purposes and the potential for worker radiation exposure was not
recognized.

The above contributory sources of inadequate, missing, or inaccurate dose records illustrates the
need to systematically review the dosimetric history, operational practice, and management
policy over the lifetime of the plant for which an SEC petition has been received, and to assure
through sampling that this probing is thorough.

The checklist in Exhibit 3-2 is divided into three sections. The first two sections allow the
auditor to review the information provided by the petitioner. The last section allows the auditor
to review the work performed by NIOSH during the petition evaluations. The first section, “SEC
eligibility criteria,” presents the conditions which must be met, by law, in order to qualify as a
member of the SEC. The second section, “Petition requirements,” presents information which
42 CER 83 states must be included in the petition in order to perform a complete evaluation. The
third section, “Information gathered by NIOSH,” is a list of sources described in 42 CFR 83 that

SC&A 3-27 Sol. No. 2003-N-00768


these developments, so that they can be given appropriate consideration as the Board fulfills its
mandate. New developments that are worth mentioning include:

.

HAT - The new model for the Human Alimentary Tract, in substitution to the
ICRP 30 Gi Tract Model, is in its final draft. It is probably going to be released in
early 2004. The new HAT model will be used in the future by ICRP in
substitution for the ICRP 30 model.

Publication of a new document, Occupational Intakes of Radionuclides: Dose
Assessment and Monitoring (Revision of Publications 30, 54, 68, 78). The new
document will contain revisions of the systemic models; most of the models will
be recycling models for easier bioassay interpretation. Whenever information is
available, physiologically based models will be recommended.

In relation to inhalation, information relating to absorption rates from the lungs to the
blood for important compounds will be recommended and other compounds will be
assigned to the three absorptions: Types F, M, S. In addition, the gender-specific
doses will be calculated using realistic computational models (phantoms), derived
from medical images, with organ sizes consistent with the new reference person
(ICRP 89, 2002).

A review of individual monitoring methods and programs, as well as interpretation of
bioassay results, will be given. A review of sources of uncertainty in the estimate of
intakes and doses will be included. A technical document on Interpretation of
Bioassay Monitoring will be published at the same time as the main document.

The biokinetic models for radionuclide contaminated wounds, which are being
developed by the National Council on Radiation Protection (NCRP), will be
reviewed by the ICRP and possibly be adopted.

A complete review of tritium compounds biokinetics is being performed and a
complete review of radon dosimetry is expected in the near future.

3.8.6' Additional Issues Related to Internal Dose Reconstruction

The reconstruction of internal dose is frequently complex, highly individualized, and defined by
variables that are largely unknown. Even when credible bioassay data exist, estimates of internal
dose(s) may, nevertheless, require process knowledge and professional judgment regarding the
applicability of standard dose models in terms of the assigned chemical form, solubility,
exposure pathway(s) for a radio-contaminant, etc. Among the variables that may profoundly
affect the uncertainty of internal dose estimates are the following:

Time of Uptake. Whole-body counting (WBC) and/or in-vitro bioassay data are
of limited value if the “day(s) of uptake” is not known. This uncertainty is
particularly problematic if the WBC/bioassay is one that is termed routine (i.e.,
conducted annually/periodically or upon termination). To assist in narrowing the
window of exposure to a most probable time period, the reviewer must consider

SC&A

3-38 Sol. No. 2003-N-00768


based on dose conversion factors that are clearly conservative based on the records, but the doses
are still found to be low, we will provide documentation of this fact.

Sometimes the opposite occurs and the use of specific factors gives a higher dose than using
default parameters. In the ICRP technical document, several examples are cited where the use of
the specific absorption factors from lung to blood gives a higher dose than when assigning the
default absorption type. All examples are related to effective doses, but the same applies with
organ doses. In cases in which there is reason to believe that the physical and chemical
composition of the inhaled or ingested material is such that the doses may be higher than
reported, this finding will be reported and given special attention with regard to its implications
not only to the dose reconstruction under investigation, but also to other related dose
reconstructions.

3.8.3 Intercomparisons of Bioassay Results among Different Laboratories

Recent intercomparisons have revealed that different laboratories can obtain different estimates
of intakes and doses when provided with the same bioassay data. In these exercises, in which the
participants had largely used ICRP models, differences in dose assessments of up to five orders
of magnitude had been reported. The differences were largely due to assumptions regarding
absorption fractions and retention models. [[AEA, “Intercomparison and Biokinetic Model
Validation of Radionuclide Intake Assessment,” IAEA-TECDOC-1071, 1999; H. Doerfel, A.
Andrasi, MLR. Bailey, A. Birchall., C.M. Castellani, C. Hurtgen, N. Jarvis, L. Johansson, B.
LeGuen, G. Tarroni,. “Third European Intercomparison Exercise on Internal Dose Assessment:
Results of a Research Pprogramme in the Framework of the EULEP/EURADOS Action Group,”
FZKA 6457, Forschungszentrum Karlsruhe, 2000.] Such findings are very disturbing, but
indicate how much the choice made by the internal dosimetry expert on “reasonable
assumptions” for missing information can affect the interpretation of bioassay results.

3.8.4 Dose per Unit Measurement for Dose Reconstruction

Graphs of committed effective dose per unit measured activity (in the body or in excreta) versus
times after intake, as a function of lung absorption Type and AMAD, reveal “areas of
invariance,” i.e., time periods where the assessment of dose is relatively insensitive to
assumptions made about lung absorption Types and AMAD. Thus, in dose-reconstruction
analysis, when AMAD and/or lung absorption Types are not known or are poorly defined, the use
of monitoring data, if available, in the period of time corresponding to the invariance area can
minimize parameter uncertainties in modeling. The effective dose per unit measured activity
also provides a tool to compare bioassay methods in relation to uncertainties in dose calculations
as a function of differences in lung absorption parameters for specific compounds. These data
are useful when choosing a bioassay method, when assigning a weight to multiple bioassay
results, and when defining the uncertainties related to an unknown or poorly known lung
absorption parameter.

3.8.5 Upcoming Developments with ICRP Internal Dosimetry

Though the current ICRP models have been adopted for use by NIOSH, ICRP is continually re-
evaluating their recommendations and models. Dr. will keep the Board appraised of

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SC&A 418 Sol. No. 2003-N-00768


SC&A

4-17

Sol. No. 2003-N-00768


Exhibit 3-2. SEC Petition Audit Report and Checklist (continued)

SEC PETITION REVIEW CHECKLIST
continued

Description [_YeyNo/NA Comments Initials |
5. “Workplace monitoring data”

I

(a) “surface contamination surveys”

(b) “general area air sampling results”

(c) “breathing zone air sampling results”

(d) “radon and/or thoron monitoring results”

(e) “area radiation survey measurements (beta, gamma
and neutron)”

(f) “fixed location dosimeter results (beta, gamma, and
neutron)”

(g) “other workplace monitoring results”

6. “Workplace characterization data”

(a) “information on the external exposure
environment:

(i) radiation type (gamma, X-ray, proton, neutron,
beta, other charged particles)

Gi) radiation energy spectrum

(iii) uniformity of exposure (whole body vs.
partial body exposure)

(iv) irradiation geometry”

(b) “information on work-required medical screening
X-rays”

(c) “other information useful for characterizing
workplace radiation exposures”

“Information characterizing internal exposures”
(a) “radionuclides and associated chemical forms”

(b) “results of particle size distribution studies”

(©) “respiratory protection practices’

(d) “other information useful for characterizing
internal exposures”

8. “Process descriptions for each work location”

(a) “general description of the process”

(b) “characterization of the source term (radionuclide
and its quantity)”

(c) “extent of encapsulation”
(d) “methods of containment”

(e) “other information to assess potential for
irradiation by source or airborne dispersion of
radioactive material”

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SC&A 48 Sol. No. 2003-N-00768


SC&A 4-14 Sol. No. 2003-N-00768


Exhibit 3-2. SEC Petition Audit Report and Checklist (continued)
SEC PETITION REVIEW CHECKLIST

‘Audit Number: | Petition Number: Date: Page ___of.

Auditors/ Area of Review:

Person(s) who performed SEC petition evaluation and/or dose reconstruction:

Description Yes/No/NA Comments ___| Initials |
SEC ELIGIBILITY CRITERIA _
Sentences or phases in quotations are items taken directly from 42 CFR 83.
Must be able to answer yes to one or more parts of the following questions in order to qualify for SEC.
1. Are the class of employees represented by the petition
present or former employees of “Department of Energy
(DOE), DOE contractor or subcontractor, or an Atomic
Weapons Employer (AWE)”?
2. Is the petitioner:
(a) a member of the class of employees?

(b) “a surviving spouse, child, parent, grandchild or
grandparent” of an employee?

(c) “one or more labor organizations representing or
formerly having represented DOE, DOE contactors,
or subcontractors, or AWE employees”?

(d) “one or more individuals or entities authorized in
writing by one or more DOE, DOE contractor or
subcontractor, or AWE employee”?

3. Have one or more members of the class of employees been
diagnosed with one or more of the following cancers:
“ (a) “Leukemia (other than chronic lymphocytic
leukemia) provided that the onset of the disease was at
least two years after initial occupational exposure”?

(b) “Lung cancer (other than in situ lung cancer that is
discovered during or after a post mortem exam”?

———

(c) “Bone cancer”?
(d) “Renal cancers”?

(e) “The following diseases, provided onset was at
least 5 years after first exposure:

( “Multiple myeloma”?

(ii) “Lymphomas (other then Hodgkin’s
Disease)”?

SC&A 3-30 Sol. No. 2003-N-00768


4.0 PERSONNEL, FACILITIES, AND EQUIPMENT
4.1 Personnel

Exhibit 4-1 presents an overview of the relevant experience of key members of the project team.
Following Exhibit 4-1, biosketches are provided that describe the role of each key person on the
project, his or her relevant project experience, and their availability to the project. Appendix A
presents complete resumes for each member of the team. Though we have assigned specific
responsibilities to each individual on the project, it is worth noting that most personnel have
experience in several of the technical specialty areas required for this project. A specific number
of hours proposed for each key person has not been given here, as there is no way to know this
without knowing the tasks which might be issued under the contract. However, work hour
allocations and schedules are provided for the sample tasks.

SC&A 4) Sol. No. 2003-N-00768


2
3
3 .
& 5
Name, Title, S 6
Anticipated Level of Effort Educational gE 3 Familiar with Specific DOE/:
(key personnel only) Background = & Facilities

SC&A H Sol. No. 2003-N-00768


Exhibit 3-2. SEC Petition Audit Report and Checklist

SEC PETITION AUDIT REPORT

Page. of,

Audit Number:

Petition Number:

==

Date:

Auditor(s):

Audit Record Summary (Describe below what records you examined, to whom you submitted them, the

conclusions you arrived at, and how you arrived at them):

List of documents reviewed:

record to this report.)

List of new documents identified: (Attach a copy of all documents not included in the original administrative

List of person(s) interviewed: (Attach a copy of the interview documentation to this report.)

Audit conclusions: A gree/disagree
(Note: Attach all audit checklists
and supporting documents.)

Agree:, (Initials)
Additional comments should be
entered in the ‘Summary’ below.

__ (initials)
If petition evaluation is rejected,
complete next section.

Disagree.

Provide a summary discussion of the reasons for disagreeing with the petition evaluation: (Attach all calculations,
notes, reports, etc., used in your conclusions.)

General Comments:

Signature of Auditor(s):

Area of Review:

Date:

:

SC&A

3-29

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SC&A 412 Sol. No. 2003-N-00768


may be used by NIOSH during its evaluation. NIOSH is responsible for collecting all relevant
information in order to accurately and fairly evaluate petitions for SEC. By definition, addition
to the SEC depends on NIOSH’s ability to do a dose reconstruction, therefore the auditor must be
able to decide if NIOSH exhausted all of the information sources and elements that make up an
accurate dose reconstruction. In most cases, performing an audit on an SEC petition evaluation
moust also involve an audit of the dose reconstruction (see the Dose Reconstruction Review
Checklist).

These completed forms will be filed in hard copy and electronic form under our records
management system, and auditable under our quality control/quality assurance program. All
audit findings are documented on the forms, and traceable back to the auditor and the documents
upon which the audit review was performed.

SC&A 3-28 Sol. No. 2003-N-00768


SC&A

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SC&A

4-15

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3.8.7

all available data that may include incident reports, radiation surveys, radiation
work permits (RWPs), co-worker exposure data, etc.

Individualize Parameters. Dose models generally are based on reference-person
physiological and lifestyle parameters. For some radionuclides, individual-
specific parameters may profoundly alter estimates of dose. For example, the
amount of dietary intake of non-radioactive iodine inversely affects the blood-to-
thyroid transfer fraction (i.e., f, value) of radioiodine. Because dietary intake of
iodine varies greatly by geographic location as well as over time, f, values can
reasonably be expected to vary from less than 0.2 to as much as 0.8 on the basis of
dietary intakes. Equally, the uptake of iodine and its retention/excretions may also
be affected by underlying thyroid conditions/pathologies. :

Use of Air Monitoring Data as Surrogate for Bioassay Data. When internal

exposures are based on air-monitoring data, the largest source of uncertainty to a
calculated dose comes from the difference in concentration(s) in air inhaled by the
worker versus the air sampled. When air is sampled in close proximity to a
specific worker (as is the case for breathing-zone apparatus), potential differences
are minimized. Of concern, however, are air monitoring data that are based on
hard-wired, permanently installed continuous air monitors (CAMs). For example,
a glove-box worker exposed in close proximity to a pinhole release of plutonium
may be breathing air concentration(s) that are one to two orders of magnitude
higher than air concentration(s) sampled by the CAM that may be 20 to 30 feet
removed from the source.

Selected Issues Related to External Dose Reconstruction

Personnel Dosimeters/Field Survey Instruments. Contributing to the uncertainty
of derived dose estimates based on personnel dosimeters (film/TLD) are many
factors. For some factors, considerable data exist that allow for corrections to be
made that minimize their contribution to uncertainty. For example, a substantial
body of data exists that defines the energy dependence of various film emulsions
used in personnel dosimeters over time.

A major factor contributing to uncertainty of personnel dosimeter and field survey
data is the method of their calibration conditions approximate to exposure
conditions of the wearer. Common variables involving calibration include
selection of the radiation source, source-to-dosimeter/instrument geometry, use of
a phantom, etc. A significant but frequently poorly defined variable is the
difference in source geometry between the calibration of the dosimeter/survey
instrument and the radiation field to which a monitored individual was exposed.
In many instances, this involves the calibration to a point source and the
monitored exposure to a complex radiation field that may include (1) multiple
independent sources, (2) an infinite planar source, (3) isotropic (27) source, or (4)
an instantaneous exposure (one side only) from a point source (i.e., prompt
neutron/gamma exposure from a nuclear weapon test).

3.8.8 Selection of Reasonable Assumptions

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